Cell phones and headphones, t-shirts and jeans – the economy may be booming but brick-and-mortar retailers are closing up shop in droves as buyers continue the long migration online for their must-have items.

In an AlixPartnerssurvey of restructuring industry participants released this January, 67% of respondents said the retail industry would be the most likely to see distress this year, taking the top spot from the oil and gas company bankruptcies that dominated headlines in 2015 and 2016.

But while many companies use Chapter 11 as a way to slash their debt and reemerge as a leaner, more efficient operation, retailers have a poor track record in bankruptcy court. That could explain why Debtwire’s 2017 Distressed Outlook survey found that just 16% of respondents anticipate the retail sector will be among the top three industries they allocate distressed investment capital to this year.

RadioShack is the latest retailer in recent months to file for “Chapter 22” – a euphemism for a second bankruptcy. General Wireless Operations, the entity that emerged with the remaining RadioShack stores from its 2015 restructuring, is now back in court hoping to restructure again – but seeking permission to liquidate all of those stores.

People walk past the Radio Shack in downtown Washington, DC, March 16, one of the 365 locations that Radio Shack intends to close by early April due to their second chapter 11 bankruptcy case in two years. (PAUL J. RICHARDS/AFP/Getty Images)

The case follows two other recent retail Chapter 22s. Wet Sealfiled again this February to ensure an orderly wind-down, less than two years after its last bankruptcy. American Apparel lasted just nine months as a reorganized company before filing its second petition in November.

Cole Schotz bankruptcy partner Ilana Volkov said the AlixPartners report is “spot on” that 2017 will be tough for retailers, but added that liquidation is not a foregone conclusion in RadioShack’s case.

“The most common theme that I can extract from these cases is that perhaps the initial restructuring might have been too optimistic and after the restructuring, the companies probably still had some of the same operational issues,” Volkov said. “Their footprint was likely still too big. The economy is still weak and consumers aren’t shopping at the same rate that the companies thought they would.”

Wet Seal, American Apparel, and Radio Shack all faced serious creditor objections in their initial bankruptcies, but Volkov says that’s not the key indicator a company will be a repeat filer. She added that the bankruptcy process provides enough oversight - between judges, US Trustees, and in most cases, an unsecured creditors committee – to ensure that a company only reorganizes if it truly appears viable.

The main issue lies with consumers, she says. “With the clothing industry, the companies need to keep up with what perhaps could be almost a daily evolution of trends, especially with younger consumers.”

Both clothing retailers blamed their initial bankruptcies on industry-wide problems, like decreased mall traffic and increased online shopping. They came back to court after discovering their reorganization efforts were too little to compete in today’s market.

RadioShack emerged from its last bankruptcy hoping that its new partnership with Sprintwould help sales. The telecom giant set up shop within RadioShack stores with an agreement to share commissions, but its sales failed to live up to expectations.

Meanwhile, another bankruptcy trend highlights the existential battle faced by retailers that seek Chapter 11 protection. An earlier study from AlixPartners – published in fall 2015 – determined that 55% of retail bankruptcies ended up in a liquidation rather than restructuring the operations into a new going concern. That combined with the string of Chapter 22s means 2017 looks to be a tough year for distressed retailers.

RadioShack sold over 2,400 stores to Standard General affiliate General Wireless Inc. in the first case, and its successor company is now back to sell at least 530 stores, and possibly all of the remaining stores. Up next in RadioShack’s bankruptcy, it has a hearing scheduled on March 29 in Delaware.